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COMPLAINT
6. That the loan obligation has lapse and the defendant defaulted in the
payment thereof and as of March 26, 2018, the total amount of the loan including
interest and penalties is now Php951,220.48 as shown by a copy of the
Statement of Account hereto attached as Annex “F”;
7. That despite demands the defendant failed and refused to settle his
obligation to the damage and prejudice of the plaintiff although under the terms of
the Promissory Note demand is no longer necessary should the defendant
renege or defaulted in the payment of any of the installment payments.
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PRAYER
Other reliefs just and equitable under the above premises are likewise
prayed for.
WILFREDO R. CORTEZ
Counsel for the Plaintiff
Sta. Cruz, Ilocos Sur
IBP No. 28105/1-17-18
PTR No. 8890557/1-4-18
Roll No. 33768
MCLE Compliance V-0013871
Issued at Pasig City
On February 11, 2016
That I have caused for the preparation of the foregoing Complaint upon
the authority of the Board of Directors hereto attached;
That all the allegations stated therein are true and correct and based on
genuine or authentic records;
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IN WITNESS WHEREOF, I have hereunto affixed my signature this
______ day of _______________, at Sta. Cruz, Ilocos Sur.
EVA B. GARNACE-BORJA
Affiant
Tin No. 147-157-262
_____________________
Notary Public
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